PRIVACY POLICY

The following policy outlines how Privada Limited Partnership, and its general partner Privada Development Inc. and their respective affiliates (collectively and individually, the “Company”) will collect, use, protect and disclose personal information. Please note that this policy also applies to Internet and e-mail applications.

WHAT IS PERSONAL INFORMATION?

Personal information is any information which can identify an individual or through which an individual’s identity can be deduced, and which is disclosed to us or which we create within the context of our relationship with the individual. Please note that Personal information does not include information which does not relate to an identified individual nor does it include an individual’s name, title, business address or business telephone number (i.e. “business card information”).

WHY DOES THE COMPANY COLLECT PERSONAL INFORMATION?HOW WILL PERSONAL INFORMATION BE USED?

In serving the needs of the Company and its employees, contractors and customers, it is important that the Company have accurate information. The Company collects and uses personal information in order to:

establish your identity

respond to your inquiries and provide you with information

provide goods and services to you and process payments

inform you of new goods and services

provide legal notices

adhere to legal requirements and comply with legal, regulatory and other obligations

carry out our business operations and for our own marketing, research, and development purposes

obtain financing

explore and/or undertake corporate opportunities, including a merger, acquisition, amalgamation, IPO, reorganization or sale of the Company, including the due diligence process and the transfer of information through to closing of any such transaction

collect debt from you

and where we are otherwise permitted or required to do so by applicable law. The Company may collect and use personal information for other purposes identified at the time of collection or use or through subsequent notice to you and your express or implied consent. The Company may also share aggregate information or de-identified information with third parties in its discretion.

HOW DOES THE COMPANY COLLECT YOUR PERSONAL INFORMATION?

We collect your personal information at the time you become a new or prospective customer, purchaser, or client of the Company and thereafter when we communicate with you. For example, we collect your personal information through:

our sales and supply agreements with you

your discussions with our agents, employees and contractors

your visits to our website and/or intranet

We may also receive personal information about you from third parties, such as any partners, affiliates, service providers, and subsidiaries we may have, and we may combine this information with any information that you provide to us.

HOW DOES THE COMPANY PROTECT PERSONAL INFORMATION?

Safeguards, security systems and processes appropriate to the sensitivity of the information are in place to protect your information. We have implemented industry standard administrative, technical and physical safeguards to protect the confidentiality, security and integrity of the personal information that we collect.

HOW LONG WILL THE COMPANY RETAIN YOUR INFORMATION?

We retain your information for only so long as is necessary for the purposes for which it has been collected. Your personal information will be destroyed once it is no longer needed by us and once all requirements at law have been met.

HAVE YOU CONSENTED?

There are some instances where we may need to disclose personal information to a third party. Whenever we engage a third party, we confirm that its privacy and security standards meet our requirements. In the event that a third party service provider is located outside of Canada, the government, courts or law enforcement or regulatory agencies of that jurisdiction may be able to obtain disclosure of your personal information through the laws of that jurisdiction.

By submitting your personal information to us, you have consented to our use and disclosure of the personal information for the purposes as outlined in this policy. If we wish to use or disclose your personal information other than as described in this policy, we will obtain your express consent before doing so.

If you prefer that we not use or disclose your personal information for any of these purposes, you may notify us in writing at any time. If you do not notify us, we will consider you to have consented to our continued use and disclosure of your personal information. A notification that we not use or disclose your personal information for certain purposes may affect our ability to provide you with goods and/or services.

Please note that from time to time, we may be compelled to release personal information as required or permitted by law.

HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION?

Your personal information, hard copy or electronic, is accessible to you. However please note that if your information is combined with information of others, you will not be granted access to such information unless we are able to segment your personal information. If your request for personal information entails a significant cost due to time, resources or copying, there may be a charge.

OUR WEBSITE

Each time you visit our website, we gather the date, time, browser type, name of visitor’s internet service provider, the site that referred the visitor to us, any pages that are requested, the navigation history and IP address of the visitor. The foregoing information does not generally contain anything that can identify users personally. We use this information for our internal audit log and system administration, and to gather broad demographic information about our user base. This information may be shared with third parties in order to provide services for aggregate use.

If you object to this gathering of information, you should not use or access our web pages.

Our website employs the use of “cookies”. A “cookie” is a small line of data that is sent to your Internet browner from a web server and stored on your computer’s hard drive. Cookies can track how and when you use a site. A cookie does not damage your system and identifies your browser, not you personally. If you do not wish to receive a cookie, use the options in your web browser.

CHANGES TO OUR PRIVACY POLICY

If we change our privacy policies and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. You are bound by changes to the Privacy Policy after those changes have been posted.

WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS OR CONCERNS ABOUT THIS POLICY?

If you have any questions or concerns about this policy, or should you wish to review your personal information, please contact the Company at: